current news organic agriculture
maandag 29 juni 2020
donderdag 4 juli 2019
zondag 22 april 2018
CHEMICAL
PESTICIDES IN FOOD
Newspaper of the Earth, October 2017. Section: Opinion
Newspaper of the Earth, October 2017. Section: Opinion
(newspaper distributed free of charge to
clients of health food shops)
Text: Jelmer Buijs; agricultural consultant and Henk Tennekes, toxicologist consultant
If you as a person want to understand these days what is in the food you are buying, you have almost a permanent job to do so. The labels of products in stores contain laundry lists of substances that you do not know and the things that are really important are often not mentioned. Farmers, processors and traders often do not know the exact composition of their products themselves, because they depend on suppliers and on the quality of the soil, water and air with which their produce is produced. Just think of the recent egg scandal with fipronil.
You want to know more
Consumers who want to know more about the substances that can be present in foods soon come home from a cold funfair. If you send e-mails to food producers, you can expect four types of answers:
• You will not receive a response
• They have never measured the substances you ask for and / or have never heard of the substances you request
• They measure these substances, but have never found anything. It is often the case that they use a very low measuring accuracy, because this is sufficient according to the law
• They do measure the substances, but do not find it in their interest to share the results of the measurements with consumers
Text: Jelmer Buijs; agricultural consultant and Henk Tennekes, toxicologist consultant
If you as a person want to understand these days what is in the food you are buying, you have almost a permanent job to do so. The labels of products in stores contain laundry lists of substances that you do not know and the things that are really important are often not mentioned. Farmers, processors and traders often do not know the exact composition of their products themselves, because they depend on suppliers and on the quality of the soil, water and air with which their produce is produced. Just think of the recent egg scandal with fipronil.
You want to know more
Consumers who want to know more about the substances that can be present in foods soon come home from a cold funfair. If you send e-mails to food producers, you can expect four types of answers:
• You will not receive a response
• They have never measured the substances you ask for and / or have never heard of the substances you request
• They measure these substances, but have never found anything. It is often the case that they use a very low measuring accuracy, because this is sufficient according to the law
• They do measure the substances, but do not find it in their interest to share the results of the measurements with consumers
Modern spraying equipment in the province of Flevoland
Recently we have e-mailed (and called) a number of companies and organizations. We asked;
1) A well-known Dutch cooperative of dairy farmers (Campina cooperative) about the presence of insecticide imidacloprid in milk.
Their
answer was: the standard for milk is 0.1 milligrams
per liter and we measure with an accuracy of 0.01 milligrams per liter. Nothing
has ever been found with this measurement accuracy.
2) A well-known beer brand from Amsterdam (Amstel Beer) about the presence of herbicides (glyphosate) in their beer.
Their answer was: It is impossible that our beer contains glyphosate, due to hard agreements with suppliers. However, they wrote further that their beer with lemon flavor can contain pesticides from the lemons. How much did they not write to us
3) A sugar factory in Dinteloord (the Netherlands) about the possible presence of insecticides (imidacloprid) in sugar and sugar products
Their Answer was simple: They had not measured this before
4) The sugar factory Südzucker in Mannheim (Germany) about the possible presence of insecticides (imidacloprid) in sugar and in bee feed that they produce.
2) A well-known beer brand from Amsterdam (Amstel Beer) about the presence of herbicides (glyphosate) in their beer.
Their answer was: It is impossible that our beer contains glyphosate, due to hard agreements with suppliers. However, they wrote further that their beer with lemon flavor can contain pesticides from the lemons. How much did they not write to us
3) A sugar factory in Dinteloord (the Netherlands) about the possible presence of insecticides (imidacloprid) in sugar and sugar products
Their Answer was simple: They had not measured this before
4) The sugar factory Südzucker in Mannheim (Germany) about the possible presence of insecticides (imidacloprid) in sugar and in bee feed that they produce.
Their
answer was: Evasive, namely that there produce meets
all European standards. They did not write how much of this substance is in
their products.
5) A large manufacturer of winter feed for bees (Dadant and Sons, USA) about the possible presence of insecticides in bee winter feed
Answer: not received
Bovenkant formulier
5) A large manufacturer of winter feed for bees (Dadant and Sons, USA) about the possible presence of insecticides in bee winter feed
Answer: not received
Bovenkant formulier
6) Skal biocontrol (Skal biocontrole is the organization
for the supervision of organic production in the Netherlands) and NVWA (the
Dutch Food and Consumer Product Safety Authority) and traders in organic food about
the levels of pesticides in organic products.
Answer: Skal;
Measured values of pesticides in organic food are not intended for the
public. Only violations are mentioned in the annual reports. The results of
residue measurements are passed on to the companies that produce these
products.
Answer from NVWA; no answer yet. NVWA responds as a rule correctly but slowly.
Trade response (via Bionext); the measured levels are not shared with consumers
Evaluation of all answers
Answer from NVWA; no answer yet. NVWA responds as a rule correctly but slowly.
Trade response (via Bionext); the measured levels are not shared with consumers
Evaluation of all answers
The cooperative of dairy farmers (with thousands of
member-producers) answered very precisely. They measure imidacloprid
insecticide in milk and comply with the legal standards, because they have
never found anything. In itself that is nice, but such a maximum allowable
concentration of this substance in milk would be fatal for many insects, such
as bees. Could it be that this milk is healthy for us ……...?
The NVWA measured in 2016 that in 37% of the tested Dutch beer brands this herbicide (glyphosate) was present with an average content of 6.5 micrograms per liter, with the highest at one beer brand of 19.1 micrograms per liter. The NVWA informed us that they could not disclose information in which beer brands this substance was found in and in which beer brands not, because this could lead to distortions of competition (as they say). Whether the well-known Amsterdam beer brand itself has measured glyphosate remains unclear in their answer. Perhaps they measure so inaccurately that they can say that they have not found anything. The NVWA considers these levels to be fully safe, even if we also ingest this substance with other foodstuffs. But what will the standards look like in 10 years?
The fact that the Dutch sugar factory has never searched for the insecticide imidacloprid in sugar can be true, although imidacloprid has been applied for years to virtually all sugar beet in the Netherlands (and in Europe). We have been told that the factory is going to measure it from now on. Then the question is whether to measure it with the correct accuracy, otherwise it does not make sense. It is very unlikely that we as consumers (or as writers of this article) will get the results of the measurements.
The German sugar manufacturer indicated that they meet all standards. However, the standards for human nutrition are much weaker than for what is required for bees (as has been mentioned before). So it is legally possible that they produce bee winter feed from which the bees become ill.
Companies that do not give a reaction at all think this will reduce the risk of negative information. That reinforces the idea that they have something to hide.
Skal biocontrole and traders in organic products (via Bionext) answered verbally that it is not the intention that the levels of pesticides in organic foods would be known by consumers.
What can you do
yourself?
By buying organically produced foods you
can limit the risk for your health. However, organic farms are also subjected
to certain levels of pesticides, via purchased non-organic manure, surface
water, rain, and through other pathways. It is important that the standards for
the use of non-organic fertilizers (by Skal biocontrol) be tightened. If it is
good, organic products should have a much lower pesticide content than
conventional products. However, this is difficult to check, because nobody
wants to publish the measurement data for organic food in the Netherlands.
Foreign research shows that organic products contain on average 4 to 5 times fewer
residues of most pesticides. So there is still work to be done for the organic
sector to make the Dutch measurements public and to ensure that the level of
pesticides is further reduced by means of various measures. These measures may
have to do with the use of manure from conventional agriculture, from compost,
but also with the use of surface water for irrigation and for drinking water
for livestock. As of 1 January 2018, biodynamic agriculture completely
prohibits the use of conventional manure. Also until that date the rules have
been stricter than with the other organic certification schemes. That is an
important step in the right direction!
There are also many applications of pesticides in and around the house. Anti-flea belts for cats and dogs are notorious because they contain large amounts of insecticides, such as imidacloprid and fipronil (well-known from the eggs), like anti-bait boxes, anti-flee shampoos, anti-fly sprays and other insect repellents. If bees would ingest these substances, only 2 of those belts would be sufficient to let all bees in the Netherlands die through chronic poisoning. It is said that alternatives based on geraniol are safe for the environment, for the pets themselves and for bees.
Cats
and dogs anti-flee belts contain very large quantities (more than 1 gram) of
the highly controversial insecticide imidacloprid and / or other substances. There is a
good destination for the belts: the collection point of chemical waste of your
municipality.
Who
can you believe?
Producers have a multitude of ways in which they can mislead consumers. In general, the claim that a product does not contain any pesticides at all is incorrect. With the right equipment you can find virtually every substance in every food. Moreover, many pesticides in the world are used in such quantities that they can be found almost everywhere in nature, also in the North Sea or in the polar ice. In certain cases, the differences between organic products and non-organic products may be small or absent;
Producers have a multitude of ways in which they can mislead consumers. In general, the claim that a product does not contain any pesticides at all is incorrect. With the right equipment you can find virtually every substance in every food. Moreover, many pesticides in the world are used in such quantities that they can be found almost everywhere in nature, also in the North Sea or in the polar ice. In certain cases, the differences between organic products and non-organic products may be small or absent;
·
if the pesticides in products originate
from applications from the distant past, eg DDT. This product will remain in
the ground for at least 100 years and will be partly absorbed by plants
·
if they are not used in the Netherlands,
but move with the wind and rain land to our fields from abroad. This takes
place everywhere, on organic and non-organic farms.
·
with the purchase of non-organic
fertilizers, straw, or via the small part (5%) permitted non-organic feed for
animals in organic livestock farming, pesticides may end up at the organic
farms
·
by the use of veterinary medicines that
in some occasions contain the same substances as pesticides used on crops
·
if producers and / or processors of
organic products do not comply with the rules, or if the rules are not right
Why does certain people say what about pesticides?
All parts of the agricultural sector that develop, research, sell and apply pesticides have an interest in telling you that they do not cause any harm and that their application would even be necessary to feed the world's population. The permitted levels of pesticides (the standards) are determined on the basis of data provided by the industry for tests on laboratory animals. In addition, research is being carried out into the effect of the substances on our ecosystem. It cannot be otherwise than that this research is very incomplete, because our ecosystem is immensely complex. The results of the ecotoxicological tests mainly provide information on the acute toxicity and in the absence of other contamination. The reality is that we use ourselves and nature as a guinea pig to observe the effect of pesticides, in addition to the tests that are done beforehand in laboratories.
Can
our economy run without pesticides?
It is absolute nonsense that our economy could not run without the use of pesticides. As a rule, organic farms have hardly any problems with diseases and pests. They apply a variety of preventive and biological measures. The yield of crops is mainly determined by the skill of the grower, by the soil fertility and by the weather. It is exactly the other way around: our economy cannot keep running with the use of all those toxins. Our soils will eventually become unusable and the food will become just as bad.
It is absolute nonsense that our economy could not run without the use of pesticides. As a rule, organic farms have hardly any problems with diseases and pests. They apply a variety of preventive and biological measures. The yield of crops is mainly determined by the skill of the grower, by the soil fertility and by the weather. It is exactly the other way around: our economy cannot keep running with the use of all those toxins. Our soils will eventually become unusable and the food will become just as bad.
What is the effect
of pesticides?
Pesticides can disturb all kinds of essential life
processes of unwanted plants (weeds), fungi, bacteria, insects and all sorts of
micro-organisms in such a way that they die. However, the operation, spreading
and possible accumulation of pesticides in nature is impossible to predict.
Moreover, everything is connected with everything in nature. The worldwide use
of imidacloprid has a lethal effect on many insects and other organisms and the
effect increases very strongly with the elapsed time. This is related to the
neurotoxicological mechanism of action of this substance, whereby the duration
of exposure enhances the ultimate effect (see first publication in the
bibliography). The chronic effect of 1 billionth of a gram imidacloprid is sufficient
to allow a bee to die within a few days. The effect of fipronil also increases
with the elapsed time, but less strongly than with imidacloprid. Fipronil is
carcinogenic in animal experiments, so in 20 years we will know more about
this, thanks to you and me (…....). It is known that carcinogenic substances do
not have a safe lower limit with regard to concentration in foodstuffs.
Why should
pesticides be avoided at all times?
Substances that have never occurred in nature do not
belong in nature and not in our body, even in very small quantities. Anyone who
says that this does not cause any damage, ignores the facts. We (also the
scientists who claim otherwise) have no idea what we are doing in nature. It
often appears that only after 20 years or more birds, butterflies or other
animals have disappeared. We also need to be very careful with natural
pesticides. Nicotine and pyrethrum are examples of natural insecticides, which are
very toxic and not selective at all.Onderkant
formulier
Do pesticides
affect your health?
The levels of pesticides in the ocean water are very
small (in the order of 1 gram per million cubic meters of water) and yet it has
been established that they can accumulate in dangerous quantities in the fat of
birds and fish that live there. Research in various countries has also shown
that large quantities of toxins accumulate in human fat tissue. The
aforementioned imidacloprid insecticide has shown in animal experiments that it
can cause obesitas, early stages of type 2 diabetes and precancer. Is it a
coincidence that these diseases are now increasing? The substance also
interacts with the human brain, and the risks that this entails are concealed.
There is hardly a product in the supermarket that doesn’t contain this
insecticide (in very small quantities). In all products containing non-organic
soya, corn, sugar, eggs and dairy products, it must be in place because it was
used in the production chain. It is also used in apple orchards, on oranges and
vegetables, etc.
What is the
influence of pesticides on nature in the Netherlands?
There have been many observations in recent years that
the number of insects is rapidly decreasing and that many birds of the farmland
are rapidly disappearing. In recent years, many meadow birds in the Netherlands
disappeared like snow in the sun. It is almost certain that the pesticides play
a major role in this. However, little research is being done, because we are
not allowed to criticize the subject of pesticides. The research is mainly at
the service of the industry and not at the service of society. Concentrations
of various pesticides in surface water in the Netherlands often exceed the
legal standards, despite the fact that these standards are already too high.
Are there strict
controls in the Netherlands?
Food samples are taken intermittently and analyzed on
pesticides by the NVWA, by Skal biocontrole and by traders. However, in some
cases it may take years before violations are discovered and published. To make
their work more effective, these organizations try to focus on risk products.
Furthermore, the NVWA and Skal biocontrol are bound by the legal MRL standards
that apply in the Netherlands. These standards are in many cases highly questionable.
Furthermore, many ‘purely vegetable’ preparations are offered for organic
farming are not checked by Skal biocontrol, if they are on the list of
permitted substances. The egg scandal has taught us that the blind faith in 'herbal'
remedies (in this case for poultry mite control in chickens) should be a thing
of the past.
The way out of
these unnecessary problems
Thousands of (organic) farmers throughout Europe are
demonstrating that they can work fine without pesticides. If we can ban all diesel
engines and coal-fired electricity plants, we can also ban the use of
pesticides over time and ensure that our offspring can look forward to the
healthiest possible future. Better turned halfway than completely gone.
Jelmer Buijs; agricultural consultant (jelmerbuijs@gmail.com)
Henk Tennekes, toxicologist consultant
(info@toxicology.nl)
Useful information:
1.
http://www.disasterinthemaking.com/about_the_author.html (book by Henk
Tennekes, 2010)
2.
https://www.waterkwaliteitsportaal.nl/Beheer/Rapportage/Bulkdata (measurements
of chemical substances in surface water in the Netherlands with measuring
points)
3. http://www.ctgb.nl/ (Board for the authorization of
plant protection products and biocides)
4. https://www.cbg-meb.nl/ (college for the evaluation
of medicines)
5. http://www.bestrijdingsmiddelenatlas.nl/
donderdag 19 april 2018
Current issues organic agriculture
ARTICLES AND PRESENTATIONS ABOUT
THE THREAT FROM PESTICIDES
TO OUR HEALTH AND ENVIRONMENT
NORMS FOR PESTICIDES IN WATER AND AGRICULTURAL
PRODUCTS. A CRITICAL REVIEW
Margriet
SAMWEL-MANTINGH1, Henk TENNEKES2, Jelmer BUIJS3
1 Women Engage for a Common Future, WECF-International,
Korte Elisabethstraat 6, 3511JG Utrecht, Netherlands (margriet.samwel@wecf.org);
Article
History:
Received 19 March 2018
Revised 25 March 2018
Accepted 28 March 2018
Keywords:
Pesticide
Maximum
tolerated levels
Risks
Food
Surface
water
|
Abstract:
There is increasing evidence that
changes in the environment and in the human health have a strong relationship
with the use of pesticides. Wild populations of birds, freshwater fish,
amphibians, reptiles, insects and several other species are declining at an
alarming speed. Society has tried to protect man and his environment with
maximum tolerated levels of pesticides in soil and water and in food.
However, these limits are rather a result of wishful thinking than of
scientific scrutiny. The authorisation procedures for pesticides have fully
ignored the impact of cumulative toxicity. The toxicity of many pesticides is
determined not only by dose but also by exposure time, and in some cases,
such as the neonicotinoid pesticides, toxicity is even reinforced by exposure
time. The alarming truth is that the dose-time-response relationship of the most
pesticides is fully unknown, since this information is not required in
official authorisation procedures. The consequence of time-dependent toxicity
is that for many pesticides the current maximum tolerated levels may
seriously underestimate actual risk. These chemicals need to be identified
and removed from the market as soon as possible. Testing should be performed
by independent organisations and authorization data should become accessible
for the public. At the same time, organic farming should be stimulated in
which synthetic pesticides are not used altogether. Almost 185.000 organic
farms in Europe prove that this is a good alternative.
|
1.
Introduction
Synthetic pesticides are a
recurring theme in all discussions about sustainable agriculture; that is no
coincidence. There is no human being on this earth who can say exactly what
impact the use of pesticides has on nature. The effects of individual active
substances and metabolites (decomposition products) on the hundreds of
thousands of organisms of our ecosystem are already impossible to predict or even
to establish. This involves several thousand substances that also interact with
each other and then have a joint effect on living organisms. Every now and then
the media pays attention to the contamination of foodstuffs with pesticide
residues or to the decline of the bee population. Recent examples are reports
on the dramatic decline of insects, fipronil in eggs, and cocktails of various
pesticides in Dutch strawberries and in honey from around the world [1].
2.
Risks of pesticides
In humans, a
strong increase of various hormone-related diseases and / or abnormalities such
as breast and prostate cancer, increased fertility, underdeveloped sexual
organs in new-borns, diabetes, and autism have been observed [2]. Also, in wild
animals worldwide observations have been made about changes caused by
hormone-disrupting chemicals (Endocrine Disrupting Chemicals - EDCs), such as
gender reassignment and malformations. There are several synthetic pesticides
that have a cancer-causing or hormone-disrupting effect. For example, prostate
cancer is associated with, among others, methyl bromide, chlorpyrifos,
phonophos, coumaphos, phorate and permethrin; alachlor with thyroid cancer.
Thyroid tumors can be caused by amitrole, ethylenethiourea, mancozeb,
acetochlor, clofentezine, fenbuconazole, fipronil, pendimethalin,
pentachloronitrobenzene, prodiamine, pyrimethanil, and thiazopyr [3].
Alzheimer's disease and other diseases are also associated with chronic
exposure to pesticides [4]. These are for people and nature alarming and
worrying developments. Nonetheless, the responsible authorities only focus on
whether or not the established norms for pesticide residues in water and food
are exceeded.
Research has
determined that synthetic pesticides also reduce soil biodiversity, such as
fungi and bacteria that are necessary for the mineralization of bound nitrogen;
This can have all kinds of consequences, such as reduced fertility of the soil
and increased dependence on artificial fertilizer. According to a report
recently published by the United Nations, pesticides do not contribute to food
security [5]. In the same document, it is concluded that pesticides have been
aggressively promoted, and their use can have very adverse consequences for the
availability of food for people. Contamination of the soil can also lead to a
disturbance of the balances in the soil between all kinds of organisms [6],
with the result that other diseases will occur as a result (directly as a
result of the use of pesticides) [7].
Many independent researchers come to the conclusion that the use of
pesticides has disastrous consequences for the ecological system and poses a
risk to people and nature, and does not even lead to food security.
3.
Authorization procedure for pesticides and standards
The Board for the Authorization of Pesticides and Biocides [8] is in the
Netherlands the authority that is responsible for the authorization of
pesticides and biocides for professional and non-professional use. The current
240 authorized active ingredients can be found in different concentrations and
combinations in no less than 2500 different products [8,9], and partly in
veterinary medicines. The same substance may in one case be authorized as a
plant protection product (pesticide) and biocide and in the other case by the
Veterinary Medicines Agency as 'veterinary medicine'. Different rules apply to
the authorization of veterinary medicines [38], in which transparent in vivo testing of ecological effects is not required
altogether.
For the authorization
of an active substance as a pesticide, the manufacturer will document the
chemical properties of the substance and carry out toxicity tests for the
substance that form the basis for the authorization procedure in the EU and
therefore also in the Netherlands. A product that comes on the market often
contains a mix of different active substances and additives to get the right
dispersion or emulsion. Possible undesirable synergistic effects between the
different substances and substances are not tested by the producer or the Dutch
Board for the Authorisation of Plant Protection Products and
Biocides (Ctgb).
Conducted toxicity tests and results are not publicly accessible.
4.
Dose-effect relationships of pesticides; the big confusion
Current admission
procedures and standards assume that an Acceptable Daily Intake (ADI) exists
for each substance. The ADI is an estimate of the amount of a substance that a
person can take on a daily basis without any significant adverse effect [10].
This approach assumes a similar dose-effect relationship for all
substances. Unfortunately, this is completely incorrect, but for the sake of
commercial interests, fundamental toxicological laws are completely ignored by
the legislators and regulators. Dose-effect relationships can be classified in
the following way:
A. Substances with
a dose-dependent action and a threshold value that do not irreversibly interact
with components of the body and for which an ADI can be established. There will
be no damage under the ADI, even under long exposure times. Admission
can be justified if the other conditions of admission can also be met, such as
degradability and absence of accumulation in the food chain.
B. Substances with a dose- and time-dependent action
without threshold, which enter into irreversible interactions with components
of the body leading to accumulating adverse effects. The product of the daily
dose d and exposure duration (until
the occurrence of a harmful effect) t
is constant: d.t = constant. This
dose-effect relationship is called Haber's rule. These substances show
cumulative toxicity and it is completely impossible to calculate an ADI for
this. Admission is irresponsible!
C. Substances with a dose- and time-dependent action
without a threshold value, which enter into irreversible interactions with
components of the body whose harmful effect not only accumulates but is also
strengthened by time.
This dose-action relationship is now known as the
Druckrey-Küpfmüller equation and can be mathematically represented by the
equation;
d.tn = constant, where n> 1. This
equation explains the harmful effects of
very low exposure concentrations of a poison at long exposure times. The lower
the exposure level, the lower the total dose required for an adverse effect.
These substances show cumulative toxicity and it is completely impossible to
calculate an ADI for this. Admission is irresponsible!
D. Substances with an unclarified (or unpublished)
dose-effect relationship. Admission is irresponsible!
4.1.
Examples of dose-effect relationships of active substances
The dose–response
relationship of the neonicotinoid insecticides imidacloprid and thiacloprid was
described in 2009 by Francisco Sánchez-Bayo for arthropods [11]. This was not
only dependent on the dose, but also on the duration of exposure. It was also
shown that the lower the exposure concentration, the lower the total dose
needed for the harmful effect (see table 1 and table 2).
In the following
table pesticides, mentioned in this article, are classified according to their
dose / time effect relationship. The dose / time effect relationship of most
pesticides has not been clarified because the current toxicological research
only aims at establishing a No-Observed Adverse Effect Level (NOAEL) as the
basis for the calculation of the ADI. Dose / time effect relationships are
almost always left out of consideration.
Understanding the
dose / time effect relationships is essential for establishing standards for
permissible concentrations of pesticides. ADIs and MRLs (Maximum Residue Limit)
can only be prepared for substances of category A. Given the fact that dose /
time effect relationships in the preparation of ADIs and MRLs have been
completely ignored, there can be no question of any confidence in the
harmlessness of substances, which belong to categories B, C and D, even in
concentrations below the ADI and MRL.
5.
Overview of legal standards for water and agricultural products
5.1.
Surface water
Depending on the
toxicity and on the occurrence of residues in surface water in practice,
maximum permissible eco-toxicological EU standards have been established for
active substances. However, the toxicity tests include a limited number of
aquatic organisms. Before the introduction of the Water Framework Directive
(WFD), there was the national MTR, Maximum Permissible Risk, in the
Netherlands. With the introduction of the European WFD (Water Framework
Directive 2000/60 / EC), the Environmental Quality Standard (EQS) is for the EU
Member States the applicable standard for many substances. At the EQS there are
two standards, respectively the:
• Annual average EQS (AA-EQS) and
• Maximum Acceptable Concentration (MAC) or EQS [12].
The AA-EQS
represents the concentration of the substance in the environment that should
provide protection against adverse effects from long-term exposure to that
substance.
Table 1: Mortality of
arthropods due to exposure to neonicotinoid insecticides (Sanchez-Bayo, 2009
[11])
Model organism
|
Test substance
|
Concentration (C) in µg.L-1
|
Time up to 50% mortality (T) in days
|
C x T product in
µg.L-1.days |
Cypridopsis vidua
|
Imidacloprid
|
4
|
5.2
|
20.8
|
16
|
3.0
|
48
|
||
64
|
3.3
|
211.2
|
||
250
|
2.3
|
575
|
||
1,000
|
2.0
|
2,000
|
||
4,000
|
0.9
|
3,600
|
||
Daphnia magna
|
Imidacloprid
|
750
|
69.7
|
52,275
|
2,220
|
18.6
|
41,292
|
||
6,700
|
15.0
|
100,500
|
||
20,000
|
18.4
|
368,000
|
||
60,000
|
3.0
|
180,000
|
||
Sympetrum striolatum
|
Thiacloprid
|
7.2
|
20,6
|
148.3
|
8.0
|
17.2
|
137.6
|
||
12.7
|
13.0
|
165.1
|
||
113.3
|
3.2
|
362.6
|
Table 2. Dose / time effect relationship of the
pesticides mentioned in this article
Dose-effect relation [13]
|
Pesticide
|
A: dose dependent
|
Of the substances mentioned
in this article no substance is known to have a dose-effect relationship that
is strictly dependent on the dose level only
|
B: d . t = constant
The
effect is determined by the total dose,
and independent of its distribution over time
|
azinphos-methyl, carbaryl,
carbofuran, fenitrothion, fipronil, methidathion, permethrin, phenthoate,
phosmet, thiacloprid
|
C: d. tn=
constant
The
lower the exposure level, the lower the total dose required for the effect
|
cartap, imidacloprid,
thiacloprid, clothianidin, thiamethoxam
|
D: not clarified
|
methyl bromide,
chlorpyrifos, fonofos, coumaphos, phorate, permethrin, alachlor, amitrol,
ethylene thiourea, mancozeb, acetochlor, clofentezine, fenbuconazole,
pendimethalin, pentachloronitrobenzene, prodiamine, pyrimethanil, thiazopyr,
Endosulfan, DDT, Endrin, glyfosaat, linuron, acetamiprid, abamectin,
aldicarb, amitraz, azinphosethyl, azinphosmethyl, azoxystrobin, captafol,
captan, carbendazim, chlorothalonil, chloridazon, chlorotoluron,
chlorpyrifos-methyl, chlorpyrifos, cyprodinil, deltamethrin, dicamba,
dichlorprop, Imazalil, iprodion, spinosad , azadirchtin, pyrethrine,
dieldrin, hexachloorbenzeen
|
The MTR and the AA-EQS focus on the
risks associated with chronic exposure via consumption of fish (products) and /
or crustaceans [14]. The MAC-EQS is aimed at the protection of aquatic
organisms with a short-term peak exposure. Individual MAC-EQS and AA-EQS
standards are not established for all substances. In those cases where the EQS
standard is missing, the MTR standard for the substance in question is used.
The legal standards for active substances in surface water can be found in,
among other things, the fact sheets of the Pesticides Atlas [15]. For surface
water no standard for the sum for individual pesticides has been set, as has
been done for drinking water.
It appears that despite all ecotoxicological standards, aquatic
organisms are insufficiently protected against pesticides. In the Netherlands,
in 2015 only 5% of the regional water bodies had a final rate of
"good" for the biological quality assessment [16]. Is this poor
quality caused by the occurrence of norm exceedances, synergistic effects of
the many substances found in the water [17]? Or do we clearly see the effects
of disregarding the dose / time effect relationships in the toxicity assessment
of substances. Or are there still other factors that play a role?
5.2. Drinking water
The acceptable
norm for pesticides in drinking water are laid down in Directive 98/83 / EC and
are applicable for all EU Member States. With a few exceptions, one and the
same norm of 0.1 μg/ l has been set for the individual active substances and
there is a norm for the total pesticides of 0.5μg/l. The norm of 0.1μg/l was
established at a time when for many pesticides the detection limit was 0.1 μg/l
and was considered as preventive standard for drinking water quality and human
health. The norms require a revision, because a concentration of 0.1 μg /l for
substances such as neonicotinoids is also dangerous if this water returns to
the environment later.
5.3.
Agricultural products for human consumption
A working group of
the European Commission intends to prepare for each active substance a
toxicological risk assessment for public health. For this risk assessment, an
estimate is made of the amount of substance that a person can take for life on
a daily basis without any noticeable effect on health [10]. This amount of
substance (mg per kg body weight - mg/kg BM) is called the Acceptable Daily
Intake (ADI). For the majority of the pesticides, an ADI has been established.
E.g. for fipronil the ADI is 0 - 0.0002 mg/kg body weight and for Imidacloprid
0 - 0.06 mg/kg body weight [18]. This means that a person weighing 50 kg daily
could take up to 0.01 mg of fipronil and 3 mg of imidacloprid via food without
any noticeable effect on his or her health.
There is also an Acute Reference Dose (ARfD). The ARfD is an estimate
for the amount of a substance in food that someone can take within 24 hours
without significant health effects. One-off consumption (of one portion) of
certain crops with relatively high residues of plant protection products (above
the ADI) can sometimes lead to acute problems. These acute problems would not
be noticed with the average consumption calculation [19].
The MRLs are laid
down in the regulation for maximum residue levels in foodstuffs EC 396/2005.
For pesticides for which no standard has been set, the MRL of 0.01 mg /kg is
usually used. No MRL or ADI has been set for the sum of the various pesticides.
If the MRL of a given substance does not exceed the ADI and ARfD, the MRL can
be included in Regulation EC 396/2005, and the substance may be authorized in
the European Union.
5.4 Packed (jar) food for infants
and toddlers
Because of their
thin skin, low weight and rapid metabolism, babies form a vulnerable group. As
a precautionary measure, therefore, within the European Union, Directive
2006/125 / EC regulates the quality of packaged (jar) food for infants and
toddlers (up to 3 years) in the EU. Jars with food for infants and toddlers
must not contain more than 0.01 mg / kg of an active substance. However, no MRL
for the sum of the various substances has been established. This means also
that 1205 times as much of the insecticide imidacloprid in baby food is allowed
than in surface water!
This means that
conventionally produced foods for infants and toddlers do not comply with the
precautionary principle (see table 5) and thus may pose a risk for this
vulnerable group. Pesticides pass through the placenta [20] and therefore
pregnant women must also be counted among the vulnerable group. In organic
farming, the use of synthetic pesticides is in principle not permitted. In this
way, these foodstuffs comply with the precautionary principle concerning
pesticide residues. Even with regard to residues in these organic foods,
however, transparency is hard to find; measurement data from the NVWA (Dutch
Food and Consumer Product Safety Authority), the Dutch inspection body for
organic agriculture (SKAL) and from Bionext[1] are all inaccessible to
the public.
5.5. Livestock feed
In the directive
for animal feed (Directive (EC) 2002/32) maximum limits for undesirable
substances such as organochlorine pesticides Endosulfan, DDT or Endrin, are
laid down for animal feed and feed materials. These substances which are very
persistent, easily soluble in fats are now banned for agricultural use, but
occur independently of the agricultural method in the food chain (through use
in the past in the Netherlands and through current use abroad). For the other pesticides
the MRLs for foodstuffs are used. These are laid down in Regulation (EC)
396/2005. Specific feed such as raw feed (hay, straw, feed corn, (silage)
grass, fodder beet, etc.) are missing in this Regulation [21].
In contrast, in
the Codex Alimentarius MRLs have been established for a number of specific
pesticides in a number of animal feed. The establishment of standards is
facilitated by the FAO and WHO [22]. The Codex Alimentarius is a basis for the
EU for setting MRLs.
6. What is the significance in case
standards are exceeded?
In the EFSA Journal
2017 [23] is mentioned that among the unprocessed plant products analysed in
the 2015 EU-coordinated control programme (EUCP), the highest MRL exceedance
rate was identified for broccoli (3.4% of the samples), followed by table
grapes (1.7%), sweet peppers (0.8%), peas without pods (0.6%), wheat (0.6%),
aubergines (0.4%) and bananas (0.3%). Moreover the foods with the highest
percentage of samples with multiple residues were bananas (58.4%), table grapes
(58.3%) and sweet peppers (24.4%). Table 5 presents for bananas some selected
MRLs, whereas the extreme high MRL of 15 mg chlorothalonil /kg bananas is remarkable.
Chlorothalonil is a fungicide of which the dose / time effect relationship is
not clarified (see table 2) and is included in the Pesticide Action Network (PAN) International List of Highly Hazardous
Pesticides [24].
The Dutch Food and
Consumer Product Safety Authority (NVWA) provides a summary of the extent to
which the legal MRLs in the tested products were exceeded in 2015. For example,
of the strawberries grown in the Netherlands, 2.6% on average exceeded the set
standard and contained on average 6.7 different pesticide residues; In the
Dutch apples tested, no MRLs were exceeded, but an average of 3.1 different
residues were found in these apples.
However, what
amount of pesticide residues can legally be present in these popular fruits? As
shown in table 4 and 5, the MRLs shown are mainly related to what remains in
practice on residues of the active substance on or in the product. For those
pesticides for which an MRL has not been specifically established, an MRL of
0.01 mg/kg is generally applicable. For the individual agricultural products,
however, no MRL is set for the sum of the different residues, while the
synergistic effect of the prevailing cocktails on pesticide residues and their
metabolites in and on foodstuffs is unknown.
So when it is
reported that a product such as apples doesn’t contain pesticide concentrations
that exceed legal standards, it says little about the actual total amount of
residues found. See Table 5 with examples of quantities of individual residues
allowed in apples and strawberries (the table shows only a small selection of
active substances and the MRLs for apples and strawberries). For example in one
kg of apples, 6 mg iprodion is legally permitted and in one kg of strawberries
20 mg; on the other hand, one kg of apples may contain 2 mg imazalil and one kg
of strawberries 0.05 mg.
The established
standards are often not logical. Another example: is there an explanation why
0.1 μg/l of fipronil may be present in drinking water, whereas for this highly
toxic substance the environmental quality standard is nearly a thousand times
lower and in root and tuber crops almost a million times higher than in surface
water? It is also not logical that the MRL for fipronil in milk is higher than
in eggs. See table 4. The consequence of
these MRL values for foodstuffs is that in principle many products in the
supermarket can be acutely toxic to our ecosystem and are considered safe by
the regulations for our health! After all, only 8.3 ng/l of imidacloprid is
allowed in surface water and 0.1 mg/l in milk (12048 times as much). This
discrepancy applies to almost all foods.
In general, a very
strict norm for aquatic environments is set, which does not seem to have any
relationship with the norms for our internal ecosystem (our metabolism).
However, there are pesticides such as imidacloprid and thiacloprid for which
there is no safe MTR or EQS for the ecosystem. These two substances are very
persistent and bind virtually irreversibly to nervous system receptors in
insects, and their toxicity is reinforced by exposure time [25]. These highly
toxic insecticides are found in large quantities in the surface water [26] and
in agricultural products. They are widely used in areas with bulb and
greenhouse cultivation, in horticulture and in arable farming. Furthermore,
they are used in ants bait boxes, neckbands for cats, dog shampoos, etc.[27, 28]
7.
Examples of environmental quality standards for pesticides in surface water and
in agricultural products
In
the Directive 2008/105/EC are (Annual
Average-) Environmental Quality Standards, Maximum Allowable Concentrations for
pesticides in surface water are defined. Some examples of the different standards and the
values for five selected pesticides are presented in table 3. A
Maximum Permissible Concentration (MPC) for fipronil in Dutch surface water has been set at
0.07 ng / L (Table 3). As a result of limitations in analytical methodology,
with detection limits usually at 10 ng/L or higher, Dutch Water Boards have
been unable to measure fipronil in surface water at concentrations up to 150
times above EQS, creating blind spots in most areas of the country. However,
the EQS for glyphosate is so high that the set MAC–EQS is seldomly exceeded.
Table 3. Examples of
standards for some pesticides in surface water (µg/l) [15]
Active agents
|
AA-EQS μg/l
|
MAC-EQS
μg/l
|
MPC
μg/l
|
Imidacloprid
|
0.0083*
|
0.2
|
--
|
Glyfosate
|
--
|
77
|
--
|
Fipronil
|
--
|
--
|
0.00007 ug/l *
|
Linuron
|
0.17
|
0.20
|
--
|
MCPA
|
1.4
|
15
|
--
|
*: The analytical
possibilities are limited; many laboratories can not measure these concentrations.
-: No concentration for
the relevant standard is mentioned in the relevant fact sheet
AA-EQS:
Annual Average-Environmental Quality Standard
MAC-EQS: Maximum Allowable Concentration - Environmental Quality
Standard
MPC: Maximum Permissible Concentration
Table 4
shows examples of maximum residue levels for the pesticides glyphosate,
fipronil and imidacloprid in some selected agricultural products. The major deficiency
of these MRLs is that the dose-response characteristics of these pesticides in
mammals are unknown. We simply don’t know whether cumulative toxicity, as seen
with fipronil and imidacloprid in arthropods, could occur in mammals as well.
If so, the MRLs would underestimate actual risk. For the cultivation of several
types of cattle feed and fodder, glyphosate is worldwide applied as an
herbicide. The set standards are not always logical. For example, although in
general the annual human consumption of milk is higher than for eggs, for the
highly hazardous insecticide fipronil the MRL in milk is higher than in one kg
eggs. These examples and those in table 5 show also that most MRLs of fresh
products don´t meet the standards of pesticide residues of 0,01 mg/kg in packed
food for infants and toddlers. This means, that the consumption of non-packed food
of non-organic origin poses a risk for infants and for toddlers.
Table 4. Examples of
MRLs for glyphosate, fipronil and imidacloprid in some agricultural products
for human consumption and for animal feed (milligrams per kg)
Agricultural product
|
Glyfosate
mg/kg
|
Fipronil
mg/kg
|
Imidacloprid
mg/kg
|
Root
and tuber crops, like carrots, beetroot; except sugar beet [29]
|
0.1
|
0.005
|
0.5
|
Pome
fruit, including apples and pears [29]
|
0.1
|
0.005
|
0.5
|
Milk [29]
|
0.05
|
0.008
|
0.1
|
Bird eggs [29]
|
0.05
|
0.005
|
0.05
|
Alfalfa fodder [22]
|
500
|
--
|
--
|
Barley straw and cattle feed (dry) [22]
|
400
|
--
|
1
|
Maize cattle feed (dry) [22]
|
150
|
0.1
|
0.2
|
Maize [22]
|
5
|
0.01
|
--
|
--
no norm established
Pesticide MRLs apply to 315 fresh
products and to the same products after processing. In case of processed
products the MRLs are adjusted in order to take account of dilution or
concentration during processing. Legislation covers pesticides currently or
formerly used in agriculture in, or outside, the EU. This are over 1300 active
ingredients [30]. In table 5 a small selection of the MRLs of pesticide
residues in the popular fruits apples, strawberries and bananas is shown. The
MRL for one and the same active substance can differ between different products
with a factor 1000, for instance in case of azoxystrobin. This is also the case
for the MRL for iprodione in strawberries and bananas.
Table 5. Examples of
MRLs established for apples, strawberries and bananas (milligrams per kg) [31]
Active agents
|
Apples
mg/kg
|
Strawberries
mg/kg
|
Bananas
mg/kg
|
|
acetamiprid
|
0.8
|
0.5
|
0,4
|
|
abamectin*
|
0.03
|
0.15
|
0,01
|
|
aldicarb*
|
0.02
|
0.02
|
0.02
|
|
amitraz
|
0.05
|
0.05
|
0.05
|
|
azinphosethyl*
|
0.02
|
0.02
|
0.02
|
|
azinphosmethyl*
|
0.05
|
0.05
|
0.05
|
|
azoxystrobin
|
0.01
|
10.0
|
2.0
|
|
captafol*
|
0.02
|
0.02
|
0.02
|
|
captan
|
10.0
|
1.5
|
0.03
|
|
carbendazim*
|
0.2
|
0,1
|
0.1
|
|
chloridazon
|
0.1
|
0.1
|
0.1
|
|
chlorothalonil*
|
2.0
|
4,0
|
15.0
|
|
chlorotoluron*
|
0.05
|
0.01
|
0.01
|
|
chlorpyrifos-methyl*
|
0.5
|
0.5
|
0.05
|
|
chlorpyrifos*
|
0.01
|
0.5
|
3.0
|
|
cyprodinil
|
2.0
|
5.0
|
0.02
|
|
deltamethrin*
|
0.2
|
0.2
|
0.01
|
|
dicamba
|
0.1
|
0.05
|
0.05
|
|
dichlorprop
|
0.02
|
0.02
|
0.02
|
|
glyphosate*
|
0.1
|
0.1
|
0.1
|
|
Imazalil*
|
2.0
|
0.05
|
2.0
|
|
imidacloprid*
|
0.5
|
0.5
|
0.05
|
|
iprodione*
|
6.0
|
20.0
|
0.01
|
*classified by Pesticide Action
Network as very toxic to humans and / or environment [24]
8. Insufficient safety to consumers
and the environment
Based on the
foregoing, it is clear that the current system of standards and control
mechanisms offers insufficient safety to consumers and the environment. A
continuation of the current policy will lead to a further disruption of our
ecosystem and in the short term also of the economy. Recent research has made
it clear that populations of meadow birds and insects [32] are disappearing at
a very high rate. In the short term, the legislator must ensure that all
pesticides from categories B, C, D in Table 2 are taken from the market until
further research by independent bodies has clarified their dose-effect
relationship. The standards for residues in foodstuffs should be based on
levels that agricultural products have today without the use of these substances
(todays background level), so that the precautionary principle is applied to
all consumers.
Many still say
that we cannot do without pesticides. There were in 2015 almost 185,000 organic
farms in Europe [33] that prove that we can work without all those risky means
of plant protection, and on average earn even better than conventional farms.
Many studies have shown that the world can be fed by agriculture without
pesticides, under the condition that we reduce our consumption of meat and the
waste of food is reduced [34, 35].
It is also true
that improvements can also be made in organic farming, also with regard to
unintentional contamination with pesticides [36,37]. Transparency is also a
prerequisite there. For conventional farming the authorization procedure for
pesticides, many of which are classified as very dangerous for humans and / or
nature, must be fundamentally changed. Toxicity testing and results of all
authorized means of plant protection must be made public. New substances may
only be authorised if they have a strictly dose-dependent dose-effect
relationship and meet all other admission criteria.
Farmers who want
to switch to organic farming must at least receive sufficient financial and
technical support during the years of conversion. Technical and practical
knowledge is now abundantly available at farms that already work organically,
in research institutions and in extension services.
8. Conclusions
The authorization
procedures of pesticides do not take into account the actual dose/time/effect
relationships of pesticides, and as a result the authorizations carry enormous
risks for people and the environment. Authorisation procedures are based on
strictly separate worlds; the human body and nature. In reality, the human body
is part of nature. The authorization does not consider any synergistic toxic
effects of additives that are added to pesticides that come onto the market. The
synergistic effects of different pesticides are not taken into account in
authorisation. In authorisation procedures, by definition, the unbelievable
complexity of nature cannot be considered.
Animal medicines
are in the EU authorized without any in vivo ecotoxicological testing. Thus,
these medicines and their metabolites end up in our ecosystem without any public
control, Therefor, new authorization procedures must be elaborated, which take
into account ecological safety and transparancy.
In the case of
authorisation of various substances (such as neonicotinoids), the Ctgb
evidently disregarded the rules that apply to the Ctgb officially: before a
plant protection product or biocide can be authorized, the Ctgb assesses
whether the product is safe for humans, animals and for the environment. Neonicotinoids are poorly
degradable, can leach and are highly toxic to many organisms.
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[38] Risicobeoordeling van diergeneesmiddelen in grondwater
bij registratie. 2009; 1-8. Available at: file:///D:/J.%20Buijs/Documents/Bestrijdingsmiddelen/diergeneesmiddelen/PNEC%20RIVM%20601711002.pdf (in Dutch)
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